HR built for Virginia behavioral health
That is the Virginia reality right now. We build documentation that holds through a DBHDS review and a regulation overhaul.
Three facts about working in Virginia
Every figure below comes from a Virginia state document or a federal dataset the state itself cites. Follow the link and read it yourself.
turnover across Virginia state psychiatric hospitals, which the legislature’s own auditor calls over twice the state government rate
In the community, Community Services Board turnover runs 19 percent, and 32 percent among peer staff. Rural CSB nursing vacancy reaches 26 percent. Virginia is the only state in the footprint required by statute to publish this every year.
What your regulator actually wrote
We read the rule text, the provider manuals, and the bulletins so you do not have to. Each quote below is copied from the primary document and linked to it.
Applications submitted for Priority 1 or 2 services without prior completion of the Initial Applicant Orientation and Comprehensive Knowledge Exam will not be reviewed under the priority timeline.
Read the source document →
The provider staffing plan shall not include volunteers or students and shall not rely on students or volunteers to supplant direct care positions.
Read the source document →
Each employee or contractor personnel record shall be retained in its entirety for a minimum of three years after the employee or contractor termination of employment.
Read the source document →
What we would fix first in Virginia
Three problems we hear from Virginia operators, the published evidence behind each one, and the program we run against it.
Virginia satisfied a federal court and still cannot staff its crisis programs.
In January 2025 Virginia moved from a twelve year Department of Justice settlement into a permanent injunction, in compliance with the large majority of provisions. Eleven months later the court’s own Independent Reviewer reported that the crisis programs built to prove community capacity were running with a fifth to two thirds of their positions empty.
The crisis arm is the emptiest part of the system
REACH is Virginia’s regional crisis service for people with developmental disabilities. It is the program that demonstrates a state can support people in the community rather than an institution.
For the reporting period ending FY2025, four regional REACH programs reported between 20 percent and 66 percent of staff positions vacant. The Independent Reviewer noted most regions were using staffing flexibly to cover.
And the community system underneath it is churning
Across all Community Services Board position types, average quarterly turnover in Q4 FY2025 was 19 percent. Peer staff ran at 32 percent, direct service providers at 27 percent, nursing at 25 percent.
Rural CSBs carry the heaviest vacancies: nursing 26 percent, peer 22 percent, direct service providers 21 percent.
If you operate in Virginia, understand that the legal pressure has eased and the staffing pressure has not. Those two things moving in opposite directions is exactly when workforce discipline gets quietly deprioritized.
Turnover by role, Community Services Boards, Q4 FY2025
The roles closest to the person receiving care are the roles turning over fastest. That is the pattern in every state we cover, and Virginia publishes it more clearly than most.
Virginia Behavioral Health Commission, STEP-VA Performance Monitoring and Evaluation Report, Report Document 663, data current as of October 15, 2025. Read the source. Derived from a 2025 survey of CSBs with 39 of 40 responding, and from CSB self reported quarterly submissions to DBHDS. Note that no single statewide CSB vacancy rate is published. DBHDS itself warns that its underlying data is self reported and that outliers should be validated before use, which is why we publish the role splits rather than one headline number.
Nine Virginia metros, and the offer a CSB is competing with
Rural CSBs carry the deepest vacancies in the Commonwealth. Pick a metro and see the arithmetic a candidate is running.
Direct care wage is the employment weighted median for front line direct care roles. The local wage floor is what the same worker can earn in retail and warehouse work in the same metro. Rent is the HUD Fair Market Rent for a one bedroom, FY2026. Full method and open data at the Direct Care Staffing Index.
Personnel is the largest component of CSB expenditures, and workforce shortages have led to increasing salaries and higher costs per visit. CSBs face substantial competition from the private sector, which often entices behavioral health professionals with higher salaries and fewer administrative duties. Even when CSBs are able to recruit qualified behavioral health professionals, they often experience high turnover rates that compound staffing challenges.
Virginia Behavioral Health Commission, STEP-VA Performance Monitoring and Evaluation Report, Report Document 663, 2025, Chapter 2, page 16. Read the source. The same chapter attributes departures partly to paperwork, assessment and data reporting burden specific to CSBs.
Virginia’s dated items
One rate change already live, one licensing chapter recently rewritten, and one oversight relationship that has changed shape.
The DOJ settlement became a permanent injunction
Virginia exited twelve years of settlement agreement oversight into a permanent injunction, in compliance with the large majority of provisions. The Independent Reviewer continues to report to the court.
The licensing regulations were amended
All of 12VAC35-105 Part III Article 4, the human resources article, was amended effective June 19, 2025. That is the chapter setting personnel records, background checks, credentialing verification, orientation timing and evaluation frequency. If your policy cites the pre-2025 text, it is stale.
The DD Waiver rate rebase took effect
DMAS updated Developmental Disability waiver rates using the 2025 Guidehouse rate study, covering Community Coaching, Community Engagement, Independent Living Supports, In-Home Support Services, Therapeutic Consultation and Workplace Assistance. New rates change what you can afford to pay, which changes what you should be offering.
Three things a Virginia provider should do now
Hit the two deadlines buried in the licensing rule
Orientation within 15 business days of employment. Tuberculosis certification within 30 days of employment or initial contact. Performance evaluation at least annually. These are the items a reviewer can check in ninety seconds, and they are the ones most often missed.
Rebuild the file to the amended 12VAC35-105-430
Individual identifying information, education and training history, employment history, and a record of any disciplinary action, retained in its entirety for three years after termination. Plus the disclosure statement, evidence of submission, the Central Criminal Records Exchange report and Child Protective Registry results under -400. Compliance Confidence™.
Fight the two reasons Virginia says people leave
The Commission named private sector pay and administrative burden. You may not win on pay. You can absolutely win on burden, and it is cheaper. Retention Reset™ starts with what your clinicians are doing that is not clinical.
Start with the Workup
A full diagnostic of your workforce across eight dimensions, scored and mapped, with the gaps ranked. It credits toward any TWF Signature Program.
Built for the organizations others find too complex
Straight answers
Do you know the DBHDS licensing regulations?
Yes. We build to 12VAC35-105, including the staffing plan, personnel record, background check, and training requirements amended in June 2025, and we track the pending overhaul that will replace the chapter.
Can you help with a new license application?
We prepare the policies, personnel systems, and documentation a DBHDS application requires. The proctored Comprehensive Knowledge Exam itself must be taken by your applicant.
How fast do you respond?
We respond to new inquiries within 2 hours.
What does the first step cost?
The Workup™ diagnostic starts at $1,750 and credits toward any TWF Signature Program.
Metro pages: Atlanta · Charlotte · Raleigh · Durham · Greenville NC · Nashville · Richmond · Jacksonville · Birmingham. Open workforce data for 90 metros lives at our public dataset.
The Virginia advisory brief
Every rule on this page, quoted in full, dated, and linked to the state document it came from.
Read the Virginia brief →Talk to an HR partner
Get a straight answer about your workforce.
We work exclusively with behavioral health and human services providers. No pitch, just a conversation about where you actually stand.
Your details stay with The Wilkinson Firm and are never sold or shared. Privacy policy.